MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge:
Respondent determined the following deficiencies and additions to tax with respect to petitioner John R. Rinn's Federal income taxes:
Additions to tax Year Deficiency Sec. 6651(a)(1) Sec. 6654 1995 $53,053 $11,888.25 $1,176.73 1996 46,471 11,617.75 2,473...
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